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U.S. Treasury Internal Revenue Code (IRC) Investment Funds

McDermott Will & Emery

The Domestic Content Bonus Credit’s Promising New Safe Harbor

McDermott Will & Emery on

On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more

Morrison & Foerster LLP

IRS Rules That Impact Investment Fund Is Not Charitable Activity

Over the last decade, impact investing has become a significant focus of many nonprofits, just as it has captured the attention of investors who care about social benefit or environmental results as much as financial results....more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Emery on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

King & Spalding

IRS and Treasury Release Final Opportunity Zone Regulations

King & Spalding on

On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Farella Braun + Martel LLP

Legal Ins and Outs of ‘Opportunity Zones’ — so Far

A new tax incentive intended to stimulate investment in low-income communities known as opportunity zones has attracted significant attention from investors, developers, and business owners since its enactment under Section...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

Bracewell LLP on

After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more

Morrison & Foerster LLP

Second Installment of Opportunity Zone Proposed Regulations Provide Additional Clarification and Guidance

On April 17, 2019, the U.S. Treasury Department and Internal Revenue Service issued a second installment of proposed regulations (the “Proposed Regulations”) relating to the Opportunity Zone Fund (“OZ Fund”) rules contained...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on

While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

UB Greensfelder LLP

IRS Issues Long-Awaited Second Round of Opportunity Zone Regulations

UB Greensfelder LLP on

As part of the 2017 Tax Cuts and Jobs Act, Congress added a new provision to the Internal Revenue Code allowing investors to defer capital gains by making investments into Qualified Opportunity Funds (QOFs). However, many...more

Smith Debnam Narron Drake Saintsing & Myers,...

UPDATE: Treasury Department Issues Highly-Anticipated Proposed Regulations on Opportunity Zones

On April 17, 2019, the United States Department of the Treasury (“Treasury”) issued its second round of proposed regulations related to investment in Qualified Opportunity Zones (“QOZs”) and Qualified Opportunity Funds...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

Foster Garvey PC on

There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Holland & Hart LLP

The Opportunity in Opportunity Zones (Infographic)

Holland & Hart LLP on

Offering significant tax breaks for investors, the federal Qualified Opportunity Zone (QOZ) program is an intriguing prospect for real estate developers and investors. However, the Treasury Department is still formalizing the...more

Parker Poe Adams & Bernstein LLP

How Investors & Real Estate Developers Can Make the Most of Qualified Opportunity Zones

Real estate developers, institutional investors, local governments, and virtually anyone with capital gains could reap significant benefits under the Qualified Opportunity Zone (QOZ) program, which Congress created as part of...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

Bowditch & Dewey on

BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update

Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more

Nelson Mullins Riley & Scarborough LLP

New Qualified Opportunity Zones Guidance: Proposed Regulations and Revenue Ruling 2018-29

The United States Treasury Department (“Treasury”) issued proposed regulations (Prop. Reg. §1.1400Z-2) (the “Proposed Regulations”) on October 19, 2018, under Section 1400Z-2 of the Internal Revenue Code, as amended, (the...more

Latham & Watkins LLP

Qualified Opportunity Funds: Investment and Structuring Considerations

Latham & Watkins LLP on

Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs. Key Points: ..Investors in qualified opportunity funds may derive significant tax benefits in the...more

Eversheds Sutherland (US) LLP

Overlooked opportunities? State tax considerations relating to investments in federal qualified opportunity zones

The year 2018 has been a monumental one for the state and local tax community. If the sweeping changes to the US federal tax code made by the federal Tax Cuts and Jobs Act of 2017 (TCJA) and continued efforts by the states to...more

Winstead PC

Opportunity Zone Regulations Update

Winstead PC on

The 2017 “Tax Cuts and Jobs Act” created the “Opportunity Zone” program to encourage investment in distressed communities. On Oct. 19, 2018, the U.S. Treasury Department and the IRS released its first significant guidance on...more

Farella Braun + Martel LLP

Treasury Department Guidance Will Stimulate Opportunity Fund Investments

The Opportunity Zones Program (OZ Program) aims to infuse capital into low-income communities known as qualified opportunity zones (QOZs) by offering tax-advantaged investments benefiting electing Qualified Opportunity Fund...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Opportunity Zones

On Oct. 18, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations under Section 1400Z-2 of the Internal Revenue Code (the “Code”) regarding qualified...more

Jones Day

Treasury Issues Guidance Clarifying Aspects of Opportunity Zone Program

Jones Day on

Much-anticipated specifics should spur investment in new program. The U.S. Treasury Department on October 19, 2018, released proposed regulations and a revenue ruling concerning the Opportunity Zone program, which was...more

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